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| The Tax Publishers2020 TaxPub(DT) 2323 (Del-Trib) : (2020) 080 ITR (Trib) 0058 INCOME TAX ACT, 1961
Section 14A
In absence of actual receipt of exempt income during the year, no disallowance under section 14A could be made.
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Disallowance under section 14A - Expenditure against exempt income - No exempt income earned during the year -
AO noticed investments in assessee's balance-sheet and accordingly, invoked section 14A so as to make disallowance. Assessee's case was that no exempt income was earned during the year.Held: As no exempt income was earned by assessee during the year, therefore, no disallowance could be made under section 14A.
Relied:Cheminvest Limited v. CIT (2015) 378 ITR 33 (Del.) : 2015 TaxPub(DT) 3520 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 2(22)(e)
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